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Financial Services Law Insights and Observations

Texas updates guidance for regulated lenders

State Issues Covid-19 Texas Consumer Credit ESIGN Lending Licensing

State Issues

On February 18, the Texas Office of the Consumer Credit Commissioner issued updated guidance (previously covered herehere,  herehere, and here) for regulated lenders relating to the Covid-19 crisis. The guidance: (1) encourages lenders to work with consumers, including by working out modifications to assist with payments, and reviewing policies for fees, late charges, delinquency practices, and repossessions, among other things; (2) reminds lenders of legal requirements for using electronic signatures; and (3) permits lenders to conduct regulated lending activity from unlicensed locations, subject to certain conditions.  The guidance is in effect through March 31, 2021, unless withdrawn or revised.

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